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Rachel, In my work, I too am having the same
“eyes glazed over” look. A provider I was on faculty with at the University of
Virginia who now is in private practice gave me this perspective. “My malpractice insurance increased
45%, my revenue decreased 12% and has every year for the last 4. The overhead
for employee health benefits increased 24% and my employees haven’t had a raise
in 2 years. I am seeing more patients; the patients themselves are taking
longer to pay so I’m not exactly sure why HIPAA even matters much if I don’t
have a practice left.” He continued,” I honestly don’t have much left to deal
with this and the only reason I’m even giving HIPAA Privacy the slightest
thought is that I am concerned that a patient will sue me if I don’t, not
because I’d go to jail. As far as Security, I’ll take my chances.” I’m paraphrasing a long
conversation, but I thought it was the most succinct assessment that I’ve heard
a small provider make. Chris Christopher P. Brancato
Compliance Officer
Director, Client Development Suite 3 503 Faulconer
Drive Charlottesville,
VA 22903-4978 434-817-9000 434-817-9006 (FAX) [EMAIL PROTECTED] www.healthdataservices.com The information contained in
this message may be privileged and/or confidential and protected from
disclosure. If the reader of this message is not the intended recipient or
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Message----- Martin,
extremely well analyzed and said. It's
interesting to me....in the last week and a half I've given a session on The
HIPAA EDI Train Wreck to a group of billing/collection agency/financial management
companies and just today an audio conference to approximately 50+ providers.
While both audiences have been extremely attentive, I came away from both
sessions feeling that this look of attention is rather a "deer in the
headlight" reaction. I will be giving this same presentation at the HIPAA
Summit West in Seattle next week. Rachel Foerster Chief Executive Officer Rachel Foerster &
Associates, Ltd. Ideas - Promotion -
Innovation Voice: 847-872-8070 email: [EMAIL PROTECTED] -----Original Message----- I hear that the AHA
"Implementation Plan" is being given consideration by CMS and
NCVHS. As one working to bring several hospitals, medium-large to small,
into compliance, I think it appropriate to comment. At first blush, the
articles (there are two, both similar, the better version is linked below) seem
to be a "pro-provider" response to the imminent train wreck.
However, on closer examination, there are some significant problems. The
suggested remedy may be worse than the original problem. They are called the
American Hospital Association, and thus they direct their remediation strategy
specifically at "the hospital." But I don't know of many
hospitals that are not part of a larger system of physician practices, clinics
and outlying facilities. Such smaller entities are facing a serious
challenge in the transition, with fewer resources to support their IT
conversion and more limited access to capital. Because the smaller entities
and their hospital(s) are fiscally bound, a solution that leaves those entities
out of the loop is certain to affect the hospital. Overall, this paper
perpetuates a number of damaging and long-refuted myths regarding HIPAA
compliance: The Myth of Understating
the Magnitude of the Individual Effects: The Myth of the
Implementation Plan The Myth of the
Achievable Testing Objective The Myth that the Payer
Is Always Right The Myth of the Error
Message The "Bad Providers
Deserve to Die" Myth Also, in the final
analysis, the "plan" itself is nearly unintelligible. Roman Numeral
III on page 7 is where I expected to find the calculation for the value of an
estimated payment. The rest of the letter seems to imply that the payment
would be based on an estimate of claims revenue (presumably after subtracting
any claims that could actually be processed). But instead, item III
does no such thing, and the steps it suggests make no sense. In fact, if
followed, they would make matters far worse. ·
In step III.1, it implies that the claims
are getting through. Providers who need the most relief will be those
whose transactions are rejected immediately for syntactical discrepencies -- a
"full bounce" of a batch of claims -- followed immediately by those
who cannot get their system (i.e. their software vendor or clearinghouse) to
produce a compliant transaction. ·
In step III.2, they assert that these
claims can somehow be adjudicated. But the contingency payments were
supposed to be for the claims that could NOT be adjudicated. ·
Finally, and worst of all, Step III.3 requires
that the provider submit the missing elements -- the unavailability of which
are the cause of the errors in the first place -- on a paper
"statement." If my system has not given me a way to send, for example, subscriber
date-of-birth, it is likely that it gives me no place to store such information. How am I
supposed to send a "statement" of information that I don't
have? More to the point, how does sending this data in a completely
nonstandard format (presumably on paper) reduce the impact of the train
wreck? Any payer with sense would deliver such reports immediately to
their shredder, so as not to waste the scarce personnel resources already
processing a mountain of paper claims, which at least are in a recognizable
format. What's more, the provider would be far better off sending a paper
claim, which doesn't REQUIRE the unavailable information. And so this avalanche of
paper claims, the much-feared root cause of the trainwreck, becomes the logical
consequence of adapting this purported "implementation plan." Next...an analysis of
the unexamined effect of the train wreck on financial markets, and a possible
alternative to perserve financial stability. Martin
Jensen IMPORTANT NOTICE: This message is intended
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